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February 1, 2021
Joseph Francella
Chief Executive Officer
Limitless Venture Group Inc.
121 E. 36th Street
Tulsa, OK 74106
Re:Limitless Venture Group Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 3
Filed January 27, 2021
File No. 024-11128
Dear Mr. Francella:
            We have reviewed your amendment and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Post-qualification Amendment No. 3 to Form 1-A filed January 27, 2021
Item 7. Description of Business, page 15
1.We note your response to prior comment 1 and revised disclosure and reissue in part. In
addition, we note your disclosure of your various acquisition agreements you entered into
recently, including Jasper Benefit Solutions, LLC, Keto Sports, Inc. and Black Ghost
Enterprises, Inc. Please file your material acquisition agreements as an exhibit to the
offering circular or tell us why it is not material. Refer to Item 17 of Part III to Form 1-A.
Market Opportunity, page 15
2.We note your updated disclosure, including the claim that, "Jasper's positioning in the
small to medium Groups market is considered largely underserved and valued at over $30
billion in the US Mid-Atlantic region alone." Please disclose the basis for this statement.

 FirstName LastNameJoseph Francella
 Comapany NameLimitless Venture Group Inc.
 February 1, 2021 Page 2
 FirstName LastName
Joseph Francella
Limitless Venture Group Inc.
February 1, 2021
Page 2
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Jason L. Drory at 202-551-8342 or Celeste Murphy at 202-551-3257
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Thomas C. Cook